Privacy Policy

Effective Date: Effective from 1st May 2024

FAIRKEYS VENTURES LLP ('Fairkeys') values the users of our website (the "Website"). Your privacy and trust are very important to us. We recognize that you may be concerned about our collection, use, and disclosure of the personally identifiable information ("Personal Information") that we collect when you use the Website and the services offered on the Website ("Fairkeys"). This Privacy Policy describes the information that we collect from you, how we collect this information, and what we do with it after we collect it. By using the Website you are accepting the practices described in this Privacy Policy. By using the Website you also give consent to the use of Your Personal Information by Fairkeys in accordance with the terms set out in this Privacy Policy. If you have any questions or comments regarding this Privacy Policy, please contact us at info@fairkeys.in.

DOES FAIRKEYS EVER MAKE CHANGES TO ITS PRIVACY POLICY?

We may make changes to the Privacy Policy from time to time. We will notify you of any material changes by sending you an email, posting a notice on the Website, or posting a notice in your account when you first login after we have made changes. If you receive notification or a change in our Privacy Policy, you must review the new Privacy Policy carefully to make sure you understand our practices and procedures. You may not be able to receive notices from us if your cookies are not set to accept and/or are disabled.

WHAT TYPES OF INFORMATION DOES FAIRKEYS COLLECT FROM ME?

Sensitive Personal Data / Information: We collect Sensitive Personal Data / Information that you provide to us, such as your name, mailing address, phone number, email address, credit card number, pan number, tan number, income tax returns, bank account number, passport details, driving license details, personal statements, reasons for seeking finance, income sources and financial information.

Non-Personal Information: We also collect non-personal information from you, such as your browser type, the URL of the previous website you visited, your ISP, operating system, and your Internet protocol (IP) Address ("Non-Personal Information"). Non-Personal Information cannot be easily used to personally identify you.

HOW AND WHEN DOES FAIRKEYS COLLECT THIS INFORMATION?

Providing Information to Us: We collect Sensitive /Personal Data / Information from you when you provide it to us. For example, if you sign up for our product or services, or make an application, we may collect your name, mailing address, telephone number, credit card number, pan number, tax identification number, tan number, income tax returns, bank account number, passport details, driving license details, personal statements, reasons for seeking an account, income sources and email address.

Communications With Us: If you communicate with us regarding the Website or Fairkeys Services, we will collect any information that you provide to us in any such communication.

Analytic and Reporting Technologies: Like the operators of most websites, we use analytic and reporting technologies to record Non-Personal Information such as Internet domain and host names, Internet protocol (IP) addresses, browser software, operating system types, clickstream patterns, and the dates and times that the Website and Fairkeys Services are accessed. We also contract with several online partners to help manage, monitor and optimize our Website and Fairkeys Services and to help us measure the effectiveness of our advertising, communications and how visitors use the Website. To do this, we may use web beacons and cookies.

HOW DOES FAIRKEYS USE MY INFORMATION?

Personal Information: We use Personal Information primarily for our own internal purposes, such as providing, maintaining, evaluating, and improving the Website, fulfilling requests for information, and providing customer support. Your personal information shall also be shared with the other members of this website. Upon acceptance of these terms and conditions, you hereby grant us an unequivocal and absolute consent to share your personal information (but not your Sensitive Personal Data / Information) with our affiliates and third parties. Fairkeys is not required to seek your consent once again in respect of sharing your personal information with our affiliates and third parties. We would further share your personal information with marketing agencies and other businesses if we in our sole discretion understand that your information may be used to market the Website or a product or service. We may also make public, your personal information in relation to any testimonials and feedback that you may provide us with and you hereby grant us the right to make such testimonials and feedback public on any public platform that we may chose. The term “Personal Information” shall include your name, address, e-mail id and mobile phone number, your images and photos, if any, but it shall not include any data in relation to your financial status, income statements, earnings, source of earnings, personal identification numbers, passwords, code numbers, bank account numbers, credit card numbers, expiry dates relationship numbers, CVV numbers, encryptions, cookies and other such electronic details.”

Non-Personal Information: We use Non-Personal Information to track the use of the Website and Fairkeys Services and for other internal purposes, such as providing, maintaining, evaluating, and improving Fairkeys Services and the Website.

WHEN WILL FAIRKEYS DISCLOSE MY INFORMATION TO THIRD PARTIES?

Disclosure to Successors: We may disclose your Personal Information to any successor-in-interest of ours, such as a company that acquires us. In the event Fairkeys goes through a business transition, such as a merger or acquisition by or with another company, or sale of all or a portion of our assets, your Personal Information will likely be among the assets transferred. You will be notified via email or by a notice on our Website of any such change in ownership or control of your Personal Information.

Disclosure to Unaffiliated Third Parties: We shall keep your personal information and Sensitive Personal Data / Information private and confidential. We may disclose your Personal Information and/or Sensitive Personal Data / Information to prevent an emergency, to respond to legal requirements, to protect or enforce our rights and policies, to protect or enforce the rights of a third party, or as required or permitted by law (including, without limitation, to comply with a summon or court order).

Disclosure to Third Party Service Providers and Online Partners: We may contract with various third parties who help us provide, maintain and improve the Website and the Fairkeys Services. For example, we use a third party to process payments made to us, and may subcontract production, fulfillment, analytics, reporting or other operations. We also contract with several online partners to help manage, monitor and optimize our Website and the Fairkeys Services and to help us measure the effectiveness of our advertising, communications and how visitors use the Website. We will use commercially reasonable efforts to prevent such third parties from disclosing your Personal Information, except for the purpose of providing Services in question. We cannot guarantee that such third parties will not disclose your Personal Information. In no circumstances, Fairkeys shall disclose data in relation to your financial status, income statements, earnings, source of earnings, personal identification numbers, passwords, code numbers, bank account numbers, credit card numbers, expiry dates relationship numbers, CVV numbers, encryptions, cookies and other such electronic details.

Disclosure of Non-Personal Information: We will disclose Non-Personal Information, in aggregate form, to potential strategic partners, advertisers, investors, customers, and others. You may opt-out of the sharing of this information by mailing us on info@fairkeys.in. However, it cannot be easily used to identify you personally.

Internet Advertising: We may use third party service providers to serve ads on our behalf across the Internet and sometimes on the Website. They may collect anonymous information about your visits to our Website, and your interaction with our products and services. They may also use information about your visits to this and other websites to target advertisements for goods and services. This anonymous information is collected through the use of a web beacon, which is industry standard technology used by most major websites.

Disclosure to Credit Rating Agencies & Reserve Bank of India: To make an improvement in its business Fairkeys may share the personal information of a user with Credit Rating Agencies and the information shall be shared with Credit Rating Agencies in the event, Reserve Bank of India issues guidelines or direction in this regard.

WHAT ABOUT COOKIES AND WEB BEACONS?

A cookie is a small file placed on the hard drive of your computer. Most websites use cookies. We use cookies to track your use of the Website and Fairkeys, provide you with a more personalized user experience, and to allow you to login and begin use of Fairkeys Services automatically when you visit the Website.

A web beacon is an often-transparent graphic image, usually no larger than a 1x1 pixel that is placed on a web page or in an e-mail that is used to monitor the behavior of the user visiting the Website or receiving the e-mail. Cookies and web beacons used by Fairkeys and our online partners are not linked to Personal Information. This Privacy Policy covers the use of cookies and web beacons by Fairkeys and does not cover the use of cookies or web beacons by any other third party, or advertiser.

DOES FAIRKEYS PROTECT MY PERSONAL INFORMATION?

Personal Information: Whenever we obtain your Personal Information, we use commercially reasonable efforts to protect it from unauthorized access or disclosure. However, we are not insurers of the security of your Personal Information. Accordingly, we assume no liability for any disclosure of data due to errors in transmission, unauthorized third party access or other acts of third parties, or acts or omissions beyond our reasonable control.

Website Content: The content that you store, post, or transmit on or through the Website, such as message board postings, storefront pages, and images on your Products, may be accessed by other users, including people that you do not know. We are not responsible for the actions of others. Therefore, you should use care in communicating with other users and only disclose your Personal Information to other users that you know to be trustworthy. You should not assume that your content will be kept private.

HOW CAN I REVIEW AND MAKE CHANGES TO MY PERSONAL INFORMATION?

You can obtain a copy of and request that we correct errors in your Personal Information by emailing us at info@fairkeys.in.

For your protection, you will be required to provide proof of your identity to obtain a copy of your Personal Information. If your Personal Information changes or if you no longer want to use the Fairkeys Services, you may correct, update or deactivate your Personal Information and/or your account through the account management screen. If you would like to deactivate or terminate your account you can also contact us at info@fairkeys.in.

Tell-A-Friend If you choose to use our referral service to tell a friend about the Website or Fairkeys Services, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Website. We store this information for the sole purpose of sending this one-time email and tracking the success of our referral program.

Security The security of your Personal Information is important to us. When you enter sensitive information such as a credit card number on our registration or order forms, we encrypt that information using secure socket layer technology (SSL).

We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Internet-based Transfers
Given that the Internet is a global environment, using the Internet to collect and process Personal Information necessarily involves the transmission of data on an international basis. By providing Fairkeys with your Personal Information you acknowledge and agree that we may store your Personal Information and transfer it to and from our servers. We endeavor to protect all Personal Information collected through the Website in a safe, confidential and secure manner.

DOES THIS PRIVACY POLICY APPLY WHEN I ACCESS THIRD PARTY WEBSITES?

You may be able to access third party websites directly from the Website. This Privacy Policy does not apply when you access third party websites. We cannot control how third parties may use Personal Information you disclose to them, so you should carefully review the privacy policy of any third party website you visit before using it or disclosing your Personal Information to its provider.

WHAT ABOUT CHILDREN'S PRIVACY?

The Fairkeys Services are intended for users ages 21 and older only. Accordingly, we will not knowingly collect or use any Personal Information from individuals that we know to be under the age of 21. In addition, we will delete any information in our database that we know originates from an Individual under the age of 21.

COLLECTION OF DEVICE LOCATION AND DEVICE INFORMATION

We collect and monitor the information about the location of your device to provide serviceability of your application, to reduce risk associated with your application and to provide offers. This also helps us to verify the address, make a better decisions and expedite know your customer (KYC) process.

Information the App collects, and its usage, depends on how you manage your privacy controls on your device. When you install the App, we store the information we collect with unique identifiers tied to the device you are using. We collect information from the device when you download and install the App and explicitly seek permissions from You to get the required information from the device.

The information we collect from your device includes the hardware model, build model, RAM, storage; unique device identifiers like IMEI, serial number, SSAID; SIM information that includes network operator, roaming state, MNC and MCC codes, WIFI information that includes MAC address and mobile network information to uniquely identify the devices and ensure that no unauthorized device acts on your behalf to prevent frauds.

We collect information about your device to provide automatic updates and additional security so that your account is not used in other people’s devices. In addition, the information provides us valuable feedback on your identity as a device holder as well as your device behaviour, thereby allowing us to improve our services and provide an enhanced customized user experience to you.

LINK TO THIRD-PARTY SDK

The App has a link to a registered third party SDK which collects data on our behalf and data is stored to a secured server to perform a financial assessment. We ensure that our third party service provider takes extensive security measures in order to protect your personal information against loss, misuse or alteration of the data.

Our third-party service provider employs separation of environments and segregation of duties and has strict role-based access control on a documented, authorized, need-to-use basis. The stored data is protected and stored by application-level encryption. They enforce key management services to limit access to data.

Furthermore, our registered third party service provider provides hosting security - they use industry-leading anti-virus, anti-malware, intrusion prevention systems, intrusion detection systems, file integrity monitoring, and application control solutions.

CHANGES IN THIS PRIVACY POLICY

We reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. In case, any changes are made in the Privacy Policy, we shall update the same on the Platform. Once posted, those changes are effective immediately, unless stated otherwise. We encourage you to periodically review this page for the latest information on our privacy practices. Continued access or use of the Services constitute Your acceptance of the changes and the amended Privacy Policy.

SECURITY PRECAUTIONS

The Platform intends to protect your information and to maintain its accuracy as confirmed by you. We implement reasonable physical, administrative and technical safeguards to help us protect your information from unauthorized access, use and disclosure. For example, we encrypt all information when we transmit over the internet. We also require that our registered third party service providers protect such information from unauthorized access, use and disclosure.

Our Platform has stringent security measures in place to protect the loss, misuse and alteration of information under control. We endeavour to safeguard and ensure the security of the information provided by you. We use Secure Sockets Layers (SSL) based encryption, for the transmission of the information, which is currently the required level of encryption in India as per applicable law. We blend security at multiple steps within our products with the state of the art technology to ensure our systems maintain strong security measures and the overall data and privacy security design allow us to defend our systems ranging from low hanging issue up to sophisticated attacks.

In addition, the Website and App have been certified for the following security certifications:

• ISO 27001 (formally known as ISO/IEC 27001:2005): is a specification for an information security management system (ISMS) and is the suggested level of certification required under the Information Technology Act, 2000. An ISMS is a framework of policies and procedures that includes all legal, physical and technical controls involved in an organization’s information risk management processes

We aim to protect from unauthorized access, alteration, disclosure or destruction of information we hold, including:

• We use encryption to keep your data private while in transit;
• We offer security feature like an OTP verification to help you protect your account;
• We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems;
• We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations;
• Compliance & Cooperation with Regulations and applicable laws;
• We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.
• Data transfers;
• We ensure that Aadhaar number is not disclosed in any manner.

We or our affiliates maintain your information on servers located in India. Data protection laws vary among countries, with some providing more protection than others. We also comply with certain legal frameworks relating to the transfer of data as mentioned and required under the Information Technology Act, 2000 and rules made thereunder When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

CAN I OPT-OUT FROM RECEIVING COMMUNICATIONS FROM FAIRKEYS?

We provide you the opportunity to opt-out of having your Personal Information used for certain purposes. For example, if you purchase a product/service but do not wish to receive any additional marketing material from us, you can indicate your preference on our order form.

If you no longer wish to receive our newsletters and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at info@fairkeys.in. We also offer you an opportunity to opt-out of certain communications through the account management screen. If you need assistance you may contact us at info@fairkeys.in.

If we choose to disclose your Personal Information to a third party in a manner that is not set forth in this Privacy Policy you will be notified so that you can make an informed choice about sharing your Personal Information with that third party.

CONSENT MECHANISM AND DATA RETENTION

By continuing to use our website or creating a Fairkeys Account, you agree to processing, storage, usage, and sharing of the data provided by you, as per the terms of this Policy. We retain and use personal information to provide you with services you explicitly requested for, to resolve disputes, troubleshoot concerns, help promote safe services, measure interest in our services, inform you about offers, products, services, updates, customize your experience, detect & protect us against error, fraud and other criminal activity, enforce our terms and conditions, etc. We may also use your personal information to send you offers regarding various services/facilities which Fairkeys or its group companies may, from time to time, start. We may occasionally ask you to complete optional online surveys. These surveys may ask you for contact information and demographic information (like zip code, age, gender, etc.). We use this data to customize your experience at Fairkeys.

If you do not agree with any of the terms of this Policy or wish to revoke any consent you have provided to us and/or our Partners, please write to us at info@fairkeys.in. You may write to us to revoke consent for use of any specific data or restrict disclosure to third parties or retention of data beyond expiry of Services or to revoke consent already granted to collect personal data and if required, make the app delete/ forget the data. However, please note that if you revoke any mandatory permissions or revoke the consent to process and store information necessary for providing services or fulfil your obligations, then we may have to cease the provision of Services to you and invoke our rights necessary to safeguard ourselves and our stakeholders. You cannot withdraw your consent once you have availed services using the website/ our App till you have closed all services with us and our Affiliates.